Plains LPG Services, LP submits FERC Form 6Q Quarterly financial report of oil pipeline companies for 2013/Q3.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Tennessee Gas Pipeline Company ) Docket No.: CP11-161 OPPOSITION OF GEORGE FEIGHNER TO TENNESSEES MOTION FOR LEAVE TO FILE AN ANSWER George Feighner, of 10 Mountain Way, Montague, NJ 07827, by his counsel, David Wallace, 399 Clove Road, Montague, NJ, 07827, states as follows by way of opposition to the Motion of Tennessee Gas Pipeline (TGP) to file an Answer to Feighners request for rehearing. TGP argues that it is providing a full record for decision by this motion. However, TGP does only three things: 1. TGP repeats only the most general conclusions about engineering solutions to fit its pipeline to the NPS Easement. 2. TGP only adds collateral documents never intended to substitute for the requisite Deed or Judgment for description of an easement. 3. TGP misstates the record and chain of title with the Sussex County Clerk by saying it amounts to a grant of limited easement rights, when the chain of title is silent on the issues up until the time of the 1974 United States Deed. Under New Jersey law, the recorded title is the only relevant chain of title. If TGP were completing the record on engineering, it would provide meaningful details on engineering inconsistencies that are clear in prior comments of Steven Vitale and based upon common sense. TGP does not. If TGP has an appropriate Deed or Judgment, it didnt record it with the partial recording in 2005 and it hasnt offered them here. The only such documents are the 1974 Deeds into United States that reserve rights-of-way for gas pipelines. If any 1955 Judgment included Page 1 B. The Record Is Inadequate To Show That TGP Cant Use The NPS Easement. ReHearing Is Required. TGP again implies that following the Administrative Procedures Act, 5 USC 500, et seq. (the APA) would be futile. This argument is simply improper. TGP still avoids the application to NPS as described in the Reichenbach letter to Sen. Toomey. By definition the matters has not been fully heard because TGP has never applied to have the issue heard before NPS. TGP adds more paper and more uncertainty with a partial filing of its 1955 condemnation records with the most important document still missing. And that would be a Deed or Judgment with a boundary and property description describing the Easement. TGP argues that its Answer would complete the record, and yet TGP never addresses the problems that jump from the Reichenbach letter ...